Peterson v. Washington County Jail

Background

The court considered the parties’ joint motions regarding continued sealing under Local Rule 5.6(d). The dispute concerned documents filed under seal in connection with discovery and other motions. The parties agreed that Docket Entries 116, 116-1, 116-2, 130-4, 130-13, 130-14, and 136 should be unsealed. They also agreed that Docket Entries 100, 100-2 through 100-14, should remain sealed because they contained personally identifying information or the names of non-party inmates.

The parties disagreed about several other entries. Peterson argued that Docket Entry 100-1 contained sensitive health information and that his privacy interest outweighed public access because the document was filed with a discovery motion rather than a motion addressing the merits. The defendants argued that the document should not remain sealed because Peterson had placed his health directly at issue. Regarding Docket Entries 130, 130-1, 130-2, 130-3, 130-5 through 130-12, 130-15, 136-1, and 136-2, Peterson identified medical, incarceration-related, and personally identifying information, as well as information about non-party inmates. He offered proposed redacted versions of several entries. The defendants argued that public access outweighed confidentiality interests and that personal information could be removed under the federal rule governing certain redactions.

Court’s Analysis

The court concluded that the need to protect the information outweighed the public’s right of access. For Docket Entry 100-1, the court relied on the private nature of the medical information and the fact that it had been submitted with a motion that did not resolve the case. The court explained that protection from public disclosure is separate from whether a party may have waived medical privilege as against an opposing party.

For the other disputed entries, the court found that medical information and information about non-parties justified continued sealing, particularly because the documents were filed with motions that did not resolve the case and most had publicly available redacted versions. The court stated that the ruling was not determinative of whether the information would remain sealed if it were later filed and considered in connection with a motion resolving the case.

Disposition

The court granted the parties’ joint motions regarding continued sealing. It ordered Docket Entries 116, 116-1, 116-2, 130-4, 130-13, 130-14, and 136 unsealed. It ordered Docket Entries 100, 100-2 through 100-14, 130, 130-1, 130-2, 130-3, 130-5 through 130-12, 130-15, 136-1, and 136-2 to remain sealed.

The discussion states that Docket Entry 100-1 should remain sealed, but the order’s numbered list of entries that will remain sealed omits Docket Entry 100-1. The opinion does not resolve whether that omission was intentional.